The Environment Agency (EA) has confirmed that the T9 waste exemption for scrap metal recovery remains valid and can still be registered.
Although the Government has restated its intention to reform the waste exemptions system, including plans to remove the T9 exemption, these changes are not yet in effect. Until the reforms are enacted, operators can continue to operate under the current T9 exemption.
If you hold both T9 and S2 exemptions, you can renew them together. When permits eventually become required, a single application can cover all relevant waste types.
Some independent consultancies have incorrectly advised that a permit is already required. This is not the case. You do not need to apply for a permit now as long as your activities remain within the current exemption conditions. The only exceptions are if:
- Your operations exceed exemption thresholds, or
- You are carrying out activities (e.g. mechanically fed shearing) not permitted under the T9 exemption.
When the exemption reforms come into force, transitional arrangements will provide operators with a 3-month window to apply for a permit. The EA will contact exemption holders directly when this happens.
An EA spokesperson said:
“For now, T9 exemption operators can still register or renew their exemptions and get their business ready for the waste exemption reforms. There have been no changes in law yet, we will keep waste exemption operators and trade associations such as the British Metal Recycling Association updated on the progress. However, T9 exemption operators will now (from July 2025) need to pay for their waste exemptions when they are registered for the first time or are renewed”.
Antonia Grey, BMRA’s Head of Policy and Public Affairs, said:
“As soon as the EA/DEFRA let us know the timeline for reforms, we will inform members about the changes. In the meantime, we will continue to work with the EA to help develop the best permitting approach for the T9 exemption and improve other scrap metal standard rules permits”.
Source www.recyclemetals.org
